New obligations were added: competent authorities must establish complaint handling procedures (Article 108) and ESMA must publish and maintain an interim MiCA register by 30 Dec 2024.
Before
There was no requirement for competent authorities to set up complaint handling procedures, and no interim MiCA register was mandated.
After
Competent authorities must set up procedures for complaints and report them to EBA and ESMA; ESMA must publish a central interim register of crypto‑asset white papers, issuers, service providers and non‑compliant entities by 30 Dec 2024 and update it regularly.
Source: ESMA — MiCA CASP Authorization & Guidance
View original source →What this means for you
Centralized Exchange
Minor changeWhy this matters
The change primarily imposes obligations on regulators (competent authorities and ESMA) rather than the CEX. However, as a service provider, the CEX will be listed on the public MiCA register, and its users will have a formalized regulatory channel for complaints.
What to do
Verify that the company's information is accurately reflected in the ESMA interim register once published.
Deadline: Dec 30, 2024
DeFi Protocol
Doesn't applyWhy this matters
The regulatory change imposes obligations on competent authorities and ESMA, not on crypto-asset service providers or issuers. Furthermore, as a fully decentralized protocol with no operator, it does not fall under the scope of entities that would be registered or subject to complaint procedures managed by these authorities.
Custodian
Minor changeWhy this matters
The change primarily imposes obligations on competent authorities and ESMA rather than the service providers themselves. However, as a crypto-asset service provider, the custodian will be listed on the public MiCA register, which affects its public regulatory standing.
What to do
Verify that the company's information is accurately reflected in the ESMA interim register once published.
Deadline: Dec 30, 2024